11 March 2025 EU adopts 16 th Sanctions Package against Russia This Circular highlights the recent key sanctions imposed against Russia by the EU and the UK. On 24 February 2025, the EU adopted the 16 th package of sanctions against Russia on the third anniversary of Russia’s full scale invasion of Ukraine. These measures are set out in several regulations and decisions which can be found here. The EU Commission has issued a press release which can be found here and FAQs which can be found here. This sanctions package targets key sectors of the Russian economy which include trade, transport, energy, infrastructure, and financial services. It also includes additional measures targeting the ‘shadow fleet’ and sanctions circumvention. The most significant measures are summarised below. Listings & Designation Criteria The EU has designated 48 individuals and 35 entities adding them to the EU sanctions list. This means that they are subject to an asset freeze and a prohibition on making funds and economic resources available to them. It has also designated 74 vessels that are part of Russia’s ‘shadow fleet’ (bringing the total number of listed vessels to 153). These are non-EU tankers that were circumventing the Russian oil price cap scheme, supporting the Russian energy sector or transporting military equipment for Russia. These vessels are subject to a port access ban, and it is prohibited for EU operators to provide a broad array of maritime services to them or to charter, operate or crew these vessels, as well as to engage in ship-to-ship transfers or any other transfer of cargo with them. The Regulation also updated the list of exclusions to the above port ban for vessels including emergency calls for safety of life at sea, humanitarian or environmental purposes. The EU has also introduced two new criteria for the designation of individuals and entities to the EU sanctions list: (1) those that own, control, manage or operate vessels in Russia’s ‘shadow fleet’ and (2) those supporting or benefitting from Russia’s military and industrial complex. Transactions ban It is prohibited to engage in any transaction, directly or indirectly, with Russian ports and locks listed in Part A of Annex XLVII of new Article 5ae of Council Regulation (EU) 2025/395 (which further amends Council Regulation (EU) 833/2014). This list includes the ports of Ust-Luga, Primorsk or Novorossiysk as they are being used for the maritime transport of Russian crude oil or petroleum products by vessels involved in “irregular and high-risk shipping practices.” It also includes the port of Astrakhan on the river Volga and Makhachkala port on the Caspian Sea, as they are being used for the transfer of Unmanned Aerial Vehicles or missiles or related technologies in support of Russia’s war against Ukraine. This prohibition is subject to various exceptions (as set out in Article 5ae (3)): “(a) in the case of a vessel in need of assistance seeking a place of refuge, of an emergency port call for reasons of maritime safety, or for saving life at sea, or for humanitarian purposes, or for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, or as a response to natural disasters; (b) to transactions which are strictly necessary for the direct or indirect purchase, import or transport of natural gas, titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into the Uni